On the 30th of November 2022, the European Commission published its proposal for the EU's Carbon Removal Certification Framework (CRCF). The proposal outlines potential EU guidelines for quantifying and verifying the climate benefits of carbon removals, in order to encourage and speed up their expansion. It also attempts to define carbon removal and form a clear foundation for developing climate-related policies in the EU.
This proposal by the European Commission is the first step. Next, Parliament and the EU Member States will review and modify this proposal before reaching a consensus and enacting the legislation (expected late 2023 or early 2024).
Importance of the CRCF
There is a clear, crucial role for the CRCF in EU climate policy. It can help certify carbon removals in the EU, and its framework can provide a basis for policymakers to implement policies that encourage and regulate carbon removal operations. Beyond policy, it can allow more carbon removal project developers the opportunity to certify carbon credits and by providing reliable certification nourish public and private financing.
Observations
The CRCF has vast potential to revolutionise carbon removals within the EU. However, a few aspects of the proposal risk undermining this objective.
Firstly, it is crucial that the CRCF correctly define carbon removals to avoid creating confusion. Unfortunately, the current definition fails to fulfil this objective, inadvertently allowing for some carbon reduction initiatives (e.g., protecting carbon sinks) to classify as carbon removals. Moreover, further clarification is needed on the criteria that determines what category (i.e., permanent removal, carbon farming, or carbon stored in products) a particular carbon removal technology falls into and how long a removal should last.
Secondly, while the CRCF identifies the need for transparency on certification, the requirements for tracking retirements could be clearer. Providing this level of traceability could elevate the framework, allowing it to overcome what has been a significant criticism of carbon markets in general.
Finally, reviews of the CRCF have called for further clarity in outlining permitted uses for different removal types to maintain virtue. For example, to prevent using short-term removals in offsetting emissions from fossil fuels.
Closing Remarks
The release of the CRCF coincides with EU-US talks on issues related to the Inflation Reduction Act, which the EU claims lures European companies to invest in the US rather than on the continent. Although the CRCF is an exciting first step, it does not yet provide direct support for removal technologies in the EU to prevent this pull. In other words, it does not mitigate the potential migration of carbon removal technology and human capital from the EU to the US that will impact the EU in the short term.
If implemented rigorously, the CRCF could open the door for the inclusion of carbon removals into compliance markets (e.g., the EU ETS), a breakthrough in accelerating carbon removals. More immediate impacts will be noticeable in the voluntary market, with project developers closely monitoring developments in the classification of removals.
Overall, we are excited about the prospect of this framework and believe that certain modifications will help ensure the EU remains at the forefront and develops the necessary infrastructure to support its climate objectives.
